Data processing for centre determined grading

Schools and colleges act as data controllers when processing the personal data of learners.

The alternative assessment arrangements for summer 2021 mean centres will process personal data for a different purpose. It is important that schools and colleges consider their legal obligations as data controllers under data protection legislation when determining grades for learners.

Section 12 of our overarching assessment guidance for summer 2021 highlighted this and included information for centres to consider in relation to data protection compliance.

Section 14 included links provided by the Information Commissioner’s Office (ICO) to their guidance on relevant sections of the UK General Data Protection Regulation (UK GDPR). The ICO guidance explains the general data protection regime that applies to schools and colleges.

We have now completed and published a data protection impact assessment (DPIA) on our decision to regulate for a centre determined grading approach for GCSEs, AS and A levels this year.

As the regulator, Qualifications Wales will not process personal data for determining grades. Nevertheless, we decided that we will conduct a full DPIA to ensure that data protection compliance has been properly assessed and any relevant impacts have been considered and mitigated as far as possible.

We have shared the DPIA with the ICO prior to publication and incorporated their feedback.

The DPIA clarifies aspects of centre determined grading, such as the legal basis for the processing. This is regarded by Qualifications Wales as being a task carried out in the public interest.

We have engaged with the Data Protection Officer network within Local Authorities who work with schools on data processing.

Schools and Colleges may wish to read and consider the DPIA content some of which may be relevant to their own processes.

This DPIA covers GCSE, AS and A levels but similar considerations should apply for other qualifications where a centre determined grading approach will be used in summer 2021.